09 Staff Report
PREPARED BY: Ying Smith
Transportation and Mobility Manager
Reviewed by: Town Manager, Assistant Town Manager, Town Attorney, Community Development
Director, and Parks and Public Works Director
110 E. Main Street Los Gatos, CA 95030 ● 406-354-6832
www.losgatosca.gov
TOWN OF LOS GATOS
COUNCIL AGENDA REPORT
MEETING DATE: 02/18/2020
ITEM NO: 9
DATE: February 10, 2020
TO: Mayor and Town Council
FROM: Laurel Prevetti, Town Manager
SUBJECT: Vehicle Miles Traveled Transition in California Environmental Quality Act
(CEQA) Analysis
a. Approve Option 2 to Set Thresholds Consistent with the General Plan
Future Year Vehicle Miles Traveled (VMT) Projections.
RECOMMENDATION:
Vehicle Miles Traveled Transition in CEQA Analysis
a. Approve Option 2 to set thresholds consistent with the General Plan future year Vehicle Miles
Traveled (VMT) projections
BACKGROUND:
On September 27, 2013, Governor Jerry Brown signed Senate Bill 743 into law and started a
process to change transportation impact analysis for purposes of CEQA compliance. The new
law directed the Governor’s Office of Planning and Research (OPR) to update the CEQA
Guidelines to include new criteria and metrics for determining the significance of transportation
impacts. OPR selected vehicle miles traveled (VMT) as the new transportation impact metric,
recommended its application Statewide, and submitted updates to the CEQA Guidelines that
were certified by the Natural Resources Agency in December 2018.
The Town of Los Gatos is the lead agency for environmental clearance under CEQA for projects
within the Town’s jurisdiction. As such, the Town is required to implement the new CEQA
Guidelines immediately, but no later than July 1, 2020. Fehr & Peers has been hired to assist
the Town in preparing its Transportation Analysis Policy and Guidelines using VMT and any
other updates to the Town’s local transportation policies, as the Council deems appropriate.
PAGE 2 OF 7
SUBJECT: Vehicle Miles Traveled Transition in California Environmental Quality Act
(CEQA) Analysis
DATE: February 10, 2020
BACKGROUND (continued):
The Town Council and Planning Commission held a joint Study Session on October 8, 2019 on
the topic as an introduction to the new requirements, concepts, and other provisions. At its
January 21, 2020 meeting, the Town Council discussed how vehicle miles travelled (VMT) and
level of service analysis (LOS) would work together in evaluating future development projects.
DISCUSSION:
The Town is working towards the adoption of its Transportation Analysis Policy and Guidelines
in compliance with the CEQA Guidelines, which would include: (1) a VMT analysis method, (2)
impact thresholds that are supported by quantitative evidence, (3) determination of whether
VMT impact screening is allowed, and (4) mitigation measures with associated VMT reduction
impacts. Attachment 1 contains Senate Bill 743 Implementation White Paper Summary for
Town of Los Gatos, which summarizes these four topic areas and options for the Town’s
consideration. In addition to the analysis method for land use projects, the Town’s
Transportation Analysis Policy and Guidelines would also address analysis for transportation
projects, Specific Plans, and General Plans. It would also include an assessment of how the
Town’s General Plan would influence future transportation analysis.
Since these four topic areas are inter-related, staff has conducted preliminary analysis on all
four questions and will present recommendations on each topic area to the Council over the
next month or two. The Town Council will have the option of revisiting prior decision points
with the final adoption of the new Policy and Guidelines. Among the four topics identified
above, an initial decision on the threshold question will inform the other three decisions and is
the subject of this report.
OPR Recommendation on the Threshold
Since SB 743 introduces a new mandatory VMT metric for use in CEQA analysis, lead agencies
need to determine what constitutes acceptable and unacceptable levels of VMT. To help aid
lead agencies with SB 743 implementation, OPR produced the Technical Advisory on Evaluating
Transportation Impacts in CEQA. OPR recommends “that a per capita or per employee VMT
that is fifteen percent below that of existing development may be a reasonable threshold.”
The legislative intent is to reduce the VMT in new developments, which would lead to a
reduction in Greenhouse Gases (GHG) and achieve the State’s climate goals. OPR concluded
that achieving 15 percent lower per capita VMT than existing developments “is both generally
achievable and is supported by evidence that connects this level of reduction to the State’s
emissions goals.” In practice, some jurisdictions can achieve this level of reduction or more
among new developments, while some jurisdictions may not. This level of reduction requires
PAGE 3 OF 7
SUBJECT: Vehicle Miles Traveled Transition in California Environmental Quality Act
(CEQA) Analysis
DATE: February 10, 2020
DISCUSSION (continued):
significant travel pattern shifts in the future, either resulting from new land uses, or from both
existing and new uses. In practice, residents and workers in these new developments would be
driving much less and finding other ways to get around, such as biking, walking, and utilizing
mass transit options.
VMT Mitigation Actions
By measuring VMT, setting a baseline, and setting targets in relation to that baseline,
jurisdictions can affect the transportation impact future development projects might have on
the environment. This allows for the jurisdiction to adopt strategies to achiev e those targets.
An important consideration is the effectiveness of the VMT mitigation actions. Based on
research conducted in suburban settings, an overall maximum reduction in VMT of 15% may be
achieved. There is a diminishing return when combining VMT mitigation actions. The most
common mitigation actions can be grouped into three categories based on their VMT reduction
effectiveness.
Actions having the most effect on VMT (and resultant emissions) derive from regional policies
related to land use location efficiency (for example providing housing near jobs) and regional
infrastructure investments that support transit, walking, and bicycling. Examples of these
actions include:
• Built environment and land use characteristics;
• Development of high density and mixed use;
• Locating land uses in close proximity to high quality transit services that connect
desirable locations with that high-quality transit, like rail and frequent bus lines; and
• Changes to relative travel costs among different modes, typically measured in time and
out-of-pocket expenses.
The second category of actions are related to site design and include such opportunities as
bicycle and pedestrian network improvements, traffic calming, local transit access
improvements, etc.
The third category of actions includes typical Transportation Demand Management (TDM)
strategies like transit fare subsidies or employer-sponsored vanpools or shuttles. While many
of these can influence VMT and emissions, they have smaller effects that are often dependent
on final building tenants and generally only apply at places of employment.
PAGE 4 OF 7
SUBJECT: Vehicle Miles Traveled Transition in California Environmental Quality Act
(CEQA) Analysis
DATE: February 10, 2020
DISCUSSION (continued):
Los Gatos Context
Los Gatos is a suburban community on the edge of an urban region. The 2015 Baseline VMT
values (Attachment 2) show that Los Gatos is not a low VMT generator. The current VMT
values result from the Town’s geographic location, regional land use density and patterns,
transportation infrastructure, and the travel behaviors as influenced by transportation costs.
The Town currently does not have a Transit Priority Area or high-quality transit corridors. The
most common transit service is a local bus. Because of this, the most effective VMT mitigation
actions are not available in Los Gatos.
Intuitively, this makes sense as Los Gatos residents commute to work, travel to larger shopping
locations, and rely on the automobile as the primary means of mobility.
As such, achieving a 15 percent reduction is extremely ambitious and unlikely for the Town,
because the most effective VMT reduction actions are not feasible given the local setting.
There is no funded major transit investment within or near Los Gatos , and no large
developments that support a jobs to housing relationship. The local context is a key
consideration in choosing the most appropriate threshold setting option.
Threshold Setting Options
Lead agencies generally have at least four options for setting VMT thresholds:
• Rely on the OPR Technical Advisory thresholds;
• Set thresholds consistent with lead agency air quality, GHG reduction, and energy
conservation goals;
• Set thresholds consistent with the General Plan future year VMT projections by
jurisdiction or region; or
• Set thresholds based on baseline VMT performance by jurisdiction.
Lead agencies may opt for a locally applicable threshold at a lower level than the OPR level, as
long as it is backed by substantial evidence, and corresponding analysis of VMT effects is
adequate and complete. The Town may consider setting its VMT thresholds consistent with its
General Plan or with Statewide goals for air quality, GHG reduction, and energy conservation.
Staff believes the following two options are most appropriate for further consideration.
• Option 1: Rely on the OPR Technical Advisory thresholds
• Option 2: Set thresholds consistent with the General Plan future year VMT projections
Table 1 provides a comparison of these two options based on various factors.
PAGE 5 OF 7
SUBJECT: Vehicle Miles Traveled Transition in California Environmental Quality Act
(CEQA) Analysis
DATE: February 10, 2020
DISCUSSION (continued):
Table 1 - Comparison of Two Options for SB 743 Implementation
Subject Option 1: Rely on the OPR Technical
Advisory thresholds
Option 2: Set thresholds consistent with
the General Plan future year VMT
projections
Thresholds Residential: 15% reduction from Town
baseline
Employment: 15% reduction from County
or regional baseline
Other land use types: TBD
Set baseline and cumulative VMT
thresholds based on long-term General
Plan expectations for air quality and GHG
emissions. The analysis to determine these
thresholds would be completed if the Town
Council selects this option.
Metrics Partial Project generated VMT for most
projects.
May need Total VMT and/or boundary
VMT for projects that don't screen out or
for unique land uses.
To be determined (TBD) based on above
analysis.
Method Most likely the VTA Travel Forecasting
Model
TBD based on above mentioned analysis.
Method would be aligned with Metrics
decision(s).
Mitigation
Actions
Options: Project-by-project mitigation
measures or a Town-wide VMT reduction
program (e.g., VMT fee, VMT Bank or VMT
Exchange)
Most likely a Town-wide VMT reduction
program (e.g., VMT fee, VMT Bank, or VMT
Exchange).
Relationship
to General
Plan Update
(GPU)
If the VMT reduction in the General Plan
update (GPU) preferred land use
alternative is higher than the OPR
thresholds, significant transportation
impacts will result. The Town will need to
adopt overriding considerations.
The GPU CEQA analysis is consistent with
the VMT significance thresholds. No
overriding consideration needed.
Evaluation of
Development
Projects
Project-by-project VMT analysis with VMT
screening. Most projects will likely have
significant transportation impacts.
CEQA streamlining provision: All projects
consistent with the General Plan will be
considered to have less than significant
impacts.
Examples San Jose, San Francisco, Oakland, and a
few others
Pasadena, Woodland
PAGE 6 OF 7
SUBJECT: Vehicle Miles Traveled Transition in California Environmental Quality Act
(CEQA) Analysis
DATE: February 10, 2020
DISCUSSION (continued):
In addition to the discussion on the thresholds, the VMT metrics and methodology are
important technical considerations in providing substantial evidence. VMT forecasts are
generated using various models that range from sketch models and spreadsheet tools to
complex computer models that account for numerous factors that influence travel demand. In
addition to several sketch models and tools, two established travel forecasting models are
available for the Town’s consideration, the Metropolitan Transportation Commission (MTC) and
the Santa Clara County Valley Transportation Authority (VTA) travel forecasting models. The
decisions on the metrics and the method must align with each other.
The Town will need to determine if projects will be able to mitigate significant VMT impacts,
and whether those measures can reduce the severity of a potential VMT impact. In the next
steps, staff will evaluate new research related to the effectiveness of the VMT mitigation
actions, review other jurisdictions’ practice(s), and compare a program-based VMT mitigation
approach with a project-by-project mitigation approach.
The Town’s General Plan update is also very relevant to the VMT transition discussion. This is a
great opportunity to consider concurrently the CEQA transportation analysis policy for
individual future developments, the General Plan future year VMT projections, and the
relationship with air quality, GHG reduction, and energy conservation goa ls.
CONCLUSION AND NEXT STEPS:
Based on review of CEQA transportation policies adopted by other jurisdictions, analysis of the
Town’s baseline VMT values, consideration for the relationship with the General Plan update,
and upon consultation with Fehr & Peers, staff is recommending proceeding with Option 2: Set
thresholds consistent with the General Plan future year VMT projections.
This option is expected to provide a threshold that is more realistic for the local context of Los
Gatos and allows the Town to take advantage of the CEQA streamlining provision. The
challenge with choosing this option is providing substantial evidence if the resulting threshold is
lower than the 15-percent reduction recommended by OPR in the Technical Advisory.
If the Town Council chooses this option, staff and Fehr & Peers will prepare the required
analyses and return with the results. The Council would then be able to consider the
thresholds, metrics, and method(s) along with applicable mitigation actions. Once the Council
decides on these factors, staff and consultants will prepare a draft Transportation Analysis
PAGE 7 OF 7
SUBJECT: Vehicle Miles Traveled Transition in California Environmental Quality Act
(CEQA) Analysis
DATE: February 10, 2020
CONCLUSION AND NEXT STEPS (continued):
Policy and Guidelines. Staff will conduct outreach to the general public and to the development
community on the Draft before bringing it for Council consideration . After the adoption of the
Transportation Analysis Policy and Guidelines, the staff and consultants will ensure alignment
with the General Plan update and bring forward potential modifications to other Town
transportation policies.
COORDINATION:
This report was coordinated with the Community Development Department.
FISCAL IMPACT:
There is no fiscal impact as a result of this report.
ENVIRONMENTAL ASSESSMENT:
This is not a project defined under CEQA, and no further action is required.
Attachments:
1. Senate Bill 743 Implementation White Paper Summary for the Town of Los Gatos
2. 2015 Baseline VMT values